B08-ATTACH 10-LBP Compliance Work Plan.pdf

ZION NATIONAL PARK

APPENDIX B

LEAD BASED PAINT COMPLIANCE

WORK PLAN

PMIS 317454, 240254, 319664, & 325305

MAY 2023

BLANK PAGE

SMITH ENVIRONMENTAL & ENGINEERING

LEAD BASED PAINT COMPLIANCE WORK PLAN

ZION NATIONAL PARK – SOUTH CAMPGROUND

SPRINGDALE, UT 84767

Prepared for DHM Design by Smith Environmental & Engineering

March 15, 2023

W W W. S M I T H D E L I V E R S. C O M

250 Perry Lane Dacono, CO 80514 phone: 720.887.4928 fax: 720.887.4680

Smith Environmental and Engineering Delivering Sustainable Environmental Solutions

LEAD BASED PAINT COMPLIANCE WORK PLAN

ZION NATIONAL PARK – SOUTH CAMPGROUND

SPRINGDALE, UT 84767

Prepared for:

DHM Design 900 S Broadway, Suite #300

Denver, CO 80209

Prepared by:

Smith Environmental and Engineering 250 Perry Lane

Dacono, CO 80514

SMITH Project No. 2020-1702

March 15, 2023 i

TABLE OF CONTENTS

INTRODUCTION

1.1 Background

1.2 Work Scope

1.3 Contractor Obligations

1.4 Activities Anticipated to impact lead-containg dust and debris

SITE PERSONNEL

2.1 Competent Person

2.2 Site Workers

WORKER PROTECTION

3.1 Respiratory Fit Testing Requirements

3.2 Establishment of the Demarcated Area

3.2.1 Work Area Preparation

3.2.2 Access to Demarcated Area

3.3 Controls and Worker Protection During Lead-Related Activities

3.4 Worker Protection During Cleanup Activities

3.5 Work Practices

3.6 Regulatory Exposure Limits

TREATMENT OF WASTE

EXPOSURE ASSESSMENT

5.1 Controls and Employee Protection During Exposure Assessment

5.1.1 Personal Protective Clothing and Equipment during Exposure Assessment

5.1.2 Hygiene Requirements during Exposure Assessment

5.1.3 Decontamination

5.2 Biological Monitoring

5.3 Training requirements during exposure assessment

5.4 Negative Initial Determination

5.5 Frequency of monitoring following negative initial determination

5.6 Positive Initial Determination

5.6.1 Lead

ii

5.7 Frequency

5.7.1 Exposures at or Above the Action Level for Lead and Below the PEL

5.7.2 Exposures Above the PEL

LEAD AIR MONITORING PROCEDURE

HOUSEKEEPING

7.1 Housekeeping Requirements

OTHER CONTRACTORS

COMPLIANCE PROGRAM FOR LEAD

9.1 Description of each Activity in which Lead is Emitted

9.2 Technology Considered in Meeting the PEL- Engineering Controls

9.3 Specific Means Employed to Achieve Compliance

9.4 Work Practice Program

9.5 Administrative Control Schedule

9.6 Arrangements made among other Contractors on the Site

CLEARANCE SAMPLING

10.1 Determination

10.2 Encapsulation

10.3 Lead Dust Wipe Sampling

REFERENCES

INTRODUCTION

1.1 BACKGROUND

Smith Environmental and Engineering (SMITH) performed a survey of lead-based paint (LBP) on 5 buildings at the Zion National Park South Campground located at 1 Zion Park Blvd, State Route 9, Springdale, UT 84767 from October 21, 2022, to May 26, 2022. Figure 1 shows the location of the Storage Building in the Zion National Park Southern Campground (Demarcated as Building S). This survey of suspect materials included visual inspections and sampling to evaluate the presence/absence of Lead Based Paint.

LBP bulk samples were analyzed by Environmental Protection Agency (EPA) Method SW 846- 3050A utilizing a Flame Atomic Absorption technique (Flame AA 7420). Lead was detected at 18.8% (SMITH 2022), above the 0.5% threshold, in the white paint sample taken from the storage building interior walls and ceiling (S-WP). The goal of this Lead Compliance Work Plan (Plan) is to provide guidance regarding the remediation of lead-containing paint inside the storage building. Following cleaning activities, lead wipe sampling will occur to meet the clearance criteria specified by the EPA (2021). Once clearance levels have been found to be below regulatory standards reoccupation of the structure may occur promptly.

1.2 WORK SCOPE

This Plan has been developed to comply with the Occupational Safety and Health Administration (OSHA) Lead in Construction Standard 29 CFR 1926.62.

This Plan provides the remediation contractor (Contractor) working on the lead dust cleanup project at Zion National Park South Campground located at 1 Zion Park Blvd, State Route 9, Springdale, UT with procedures and work practices for operations that impact lead-containing dust. This Plan seeks to minimize hazards associated with exposure to lead because of cleanup activities. This Plan includes requirements for engineering controls, work practices, personal protective equipment, respirator protection, and air monitoring associated with activities that impact lead-containing dust. Figure 2 shows the locations of LBP within the Storage Building.

1.3 CONTRACTOR OBLIGATIONS

The Contractor shall familiarize themselves with the conditions of the site. Each employee performing work onsite is required to sign Appendix 1 – Employee Acknowledgement. Each contractor working within the regulated lead work area is required to complete and sign Appendix 2 – Task Specific Activity Log prior to commencement of work.

1.4 ACTIVITIES ANTICIPATED TO IMPACT LEAD-CONTAING DUST AND DEBRIS

It is anticipated that the following activities will impact the lead-containing dust during cleaning activities:

• Collection and removal of debris

• Cleaning lead-contaminated dust from building contents, equipment, and surfaces.

3/15/2023 Smith Environmental and Engineering Zion National Park South Campground

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SITE PERSONNEL

2.1 COMPETENT PERSON

The competent person (CP) shall be designated by the Contractor and shall have the authority to immediately halt work during the exposure assessment phase if the provisions of this Plan are not met. The CP shall be required to perform the following duties:

• Ensure all work is performed in compliance with the policies and procedures outlined in this Plan and applicable state and federal regulations.

• Record any illness, disease, injury, pulmonary disorder, or death of any person on site.

• Control entry and exit to the demarcated area.

• Supervise all air monitoring.

• Ensure that employees working within the demarcated area have been provided a copy of this work plan, and wear protective clothing and respirators, as required by applicable regulations and this Plan.

• Ensure that employees use the hygiene facilities and observe the decontamination procedures specified in this Plan.

• Ensure that engineering controls are functioning properly.

• Perform safety record keeping.

2.2 SITE WORKERS

Site workers shall be required to perform the following duties:

• Read and follow this Plan.

• Check all personal safety equipment to ensure it is in good working condition.

• Immediately report any accidents, illness, spills, unsafe conditions, and any unusual smells to the CP.

• Be familiar with, and confident working in, respiratory protection.

WORKER PROTECTION

Section 3 applies to all employees who will be entering the demarcated areas (see section 3.2.1) and is intended to meet all requirements of OSHA 29 CFR 1926.62 (OSHA 2007).

3.1 RESPIRATORY FIT TESTING REQUIREMENTS

Respiratory protection shall be utilized in accordance with 29 CFR 1926.62 (OSHA 2007). and 29 CFR 1910.134 (OSHA 1971). Workers required to wear respirators shall train in respirator use and medically approved to wear a respirator.

3.2 ESTABLISHMENT OF THE DEMARCATED AREA

Section 3.2 describes the requirements for access and demarcating work areas where the potential for lead exposure exists.

3.2.1 Work Area Preparation

The work area shall be clearly demarcated with red or yellow hazard/warning tape during the exposure assessment phase of the project. The demarcated area shall include a perimeter sufficient to perform the work. The demarcated area shall consist of the pathway for transport of any lead-contaminated material to a stockpile or storage receptacle if the debris is not immediately transported from the site.

Polyethylene drop sheets, of 6 millimeters or greater thickness, will be placed in areas where the generation of lead dust is anticipated. Critical barriers will be installed to prevent the migration of dust generated during cleaning operations. Local exhaust ventilation may be necessary to prevent resettling of dust during cleaning operations.

If at any time during the project the permissible exposure limit (PEL) for lead is exceeded, signs shall be posted in each such work area stating:

DANGER

LEAD

MAY DAMAGE FERTILITY OR THE UNBORN CHILD

CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM

DO NOT EAT, DRINK OR SMOKE IN THIS AREA

Prior to beginning work, all porous personal items shall be cleaned using appropriate HEPA vacuuming and or wet wiping methods and stored in a clean area for retrieval. As feasible, personal items should be wipe sampled for lead content prior to release to their owners. If wipe sampling indicates lead contamination, personal items should be re-cleaned or disposed of appropriately.

3.2.2 Access to Demarcated Area

No one is permitted to enter the demarcated area without the approval of the CP. All persons entering the demarcated area are required to be trained in accordance with section 5.3 and comply with all sections of this Plan.

During the initial exposure assessment phase of the project (see section 5.0), no employee shall be allowed to enter the demarcated area without complying with the provisions outlined in section 3.0 and 5.0. If the exposure assessment determines exposures to be below the action level for lead, other personnel may be allowed to enter the control area; however, access may be limited to those personnel with work duties that require them to be present in the demarcated area.

While within the demarcated area, all eating, drinking, smoking, chewing gum or tobacco, and applying of cosmetics shall be strictly prohibited.

All persons entering the demarcated area shall sign an entry/exit log.

3.3 CONTROLS AND WORKER PROTECTION DURING LEAD-RELATED ACTIVITIES

The requirements outlined in this section shall apply to all lead-related activities where there is the potential for lead exposure.

Until the exposure assessment determines worker exposure to be below the action level during cleanup activities, appropriate personal protective clothing and equipment shall be required.

This shall include, but not be limited to the following:

Task PPE Minimum Respiratory Protection

Engineering Controls / Equipment

Cleanup of lead-containing dust and debris

Disposable coveralls, eye protection, gloves

Half-face, air-purifying respirators with P100 filters

Demarcation tape, HEPA vacuums, polyethylene drop sheets, HEPA-filtered air scrubbers

3.4 WORKER PROTECTION DURING CLEANUP ACTIVITIES

After operations impacting lead-containing dust and debris are completed, drop sheets and collection material shall be removed from the demarcated area. In addition, cleanup of any lead-containing dust and debris, which was not collected by the drop sheet, shall be performed using a high efficiency particulate air (HEPA) filtered vacuum or wet wiping. Dry sweeping is prohibited.

During the removal of the drop sheets and debris cleanup, appropriate protective clothing and equipment shall be required. This shall include but not be limited to coveralls or similar full-body work clothing, gloves, and appropriate eye protection. Respiratory protection shall consist of a half-mask air-purifying respirator equipped with P100 filters.

3.5 WORK PRACTICES

Specific work practices for the removal of lead-containing dust and debris shall be developed by the Contractor. At a minimum, the following work practices shall be used:

• Wet methods

• HEPA vacuums

• Scrub brushes

• Cleaning detergent

• Disposable rags

• Local exhaust ventilation

The Contractor should generally follow guidelines as outlined in Chapter 14: Cleaning of the U.S.

Department of Housing and Urban Development Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (HUD 2012). Furthermore, please see Appendix 2: Lead Compliance Activity Log. All contractors shall read and fill out this form before beginning any operations that may impact lead-containing dust and debris at the site. At a minimum, this shall include a three-stage cleaning procedure:

1. HEPA vacuum of surfaces

2. Wet cleaning using a detergent

3. HEPA vacuum surfaces again after one hour from wet cleaning

In circumstances where this three-stage cleaning process does not adequately remove dust, then the least invasive procedure should be used, preferably in conjunction with a HEPA vacuum to limit release of lead-containing dusts.

To prevent surfaces from being recontaminated during the cleaning process, contractor shall work from “top to bottom” while cleaning. Cleaning shall begin at the highest level and proceed from ceiling to walls to floor to avoid recontamination of previously cleaned surfaces.\

3.6 REGULATORY EXPOSURE LIMITS

OSHA has set forth an action limit for lead of 30 micrograms per cubic meter of air (μg/m3) and a PEL of 50 μg/m3.

TREATMENT OF WASTE

All lead-containing dust and debris, polyethylene sheeting, wastewater, and disposable personal protective equipment shall be collected and will be sampled for waste characterization by others.

Waste characterization will include toxicity characteristic leaching procedure (TCLP) sampling for lead as specified in The American Society for Testing and Materials (ASTM) E1908-16 (ASTM 2020c).

The Contractor shall pay strict attention to the requirements of 40 Code of Federal Regulation (CFR) 262 and 40 CFR 265 (CFR 2023) for the on-site handling of potentially contaminated debris.

Waste stored on-site determined to be hazardous shall be properly containerized, labeled, and stored within a demarcated area.

EXPOSURE ASSESSMENT

This section outlines requirements for assessing whether the work operations listed in this Plan result in an employee exposure to lead at or above the action level and permissible exposure limit.

As outlined in section 6.0 of this Plan, for each workplace or work operation listed in this Plan, the CP shall initially determine if any employee may be exposed to lead at or above the action level and permissible exposure limit using air monitoring. Personal samples shall be representative of a full shift including at least one sample for each job classification in this Plan.

5.1 CONTROLS AND EMPLOYEE PROTECTION DURING EXPOSURE ASSESSMENT

5.1.1 Personal Protective Clothing and Equipment during Exposure Assessment The following is a summary of the personal protective clothing and respirator required for each operation until the exposure assessment is complete. For a more complete description of the required personal protective clothing and respirators, refer to section 3.0 of this Plan (Worker Protection).

Task PPE Minimum Respiratory Protection

Engineering Controls / Equipment

Cleanup of lead-containing dust and debris.

Disposable coveralls, eye protection, gloves.

Half-face, air-purifying respirators with P100 filters.

Demarcation tape, HEPA vacuums, polyethylene drop sheets, HEPA-filtered air scrubbers.

5.1.2 Hygiene Requirements during Exposure Assessment

Until the exposure assessment is complete for each work operation where an employee may be exposed to lead, the following procedures shall be implemented.

Change areas shall be provided and are required to be used. Change areas shall be equipped with separate storage facilities for protective work clothing and equipment and for street clothes. Each employee who enters a demarcated area during the exposure assessment shall not leave the workplace wearing any protective clothing or equipment that is required to be worn during the work shift.

Hand washing facilities shall be provided and shall be required to be used. Hand washing facilities shall be located near the entrance to the demarcated area, where possible, for access by employees who are required to work in the demarcated areas. On-site lavatories may be utilized as hand washing facilities as permitted by the Owner.

If it is determined that the workers are being exposed above the lead PEL of 50 μg/m3, a shower facility shall be required.

5.1.3 Decontamination

Surface dust on work clothing shall be removed by vacuuming or other cleaning method, or placement of disposable coveralls into waste receptacle prior to exiting the regulated work area.

Workers shall then proceed to the changing area and washing facilities prior to any activity not related to work. Equipment brought outside the work area shall be decontaminated using wet wipe methods and/or HEPA vacuuming.

Decontamination waste shall be packaged, stored, and labeled by the Contractor. All waste will have a hazardous waste characterization performed by TCLP prior to disposal.

5.2 BIOLOGICAL MONITORING

Section 5.2 applies to each employee who is required to enter the demarcated area during the exposure assessment phase of the project.

Biological monitoring for exposure to lead shall consist of blood sampling and analysis for lead and zinc protoporphyrin levels. Biological monitoring shall be made available within 48 hours of the onset of exposure. If air sample results are received within 48 hours and indicate exposure below the action level of 30 μg/m3 for the activity monitored (as required by this section), biological monitoring is not required.

If employees are exposed above the lead action level for 30 days or more during any consecutive 12-month period, regardless of respirator use, full medical monitoring shall be provided. This monitoring shall consist of the following:

1. Blood sampling and analysis for lead and zinc protoporphyrin levels. This monitoring shall be required every two months for the first six months and every six months thereafter.

2. A detailed work history and medical history with particular attention to past lead exposure, personal habits, and past gastrointestinal, hematological, renal, cardiovascular, reproductive, and neurological problems.

3. A thorough physical examination, with particular attention to teeth, gums, hematological, gastrointestinal, renal, cardiovascular, neurological, and pulmonary systems.

4. A blood pressure measurement.

5. A routine urinalysis with microscopic examination.

6. Any laboratory or other test relevant to lead exposure that the examining physician deems necessary by sound medical practice.

The Contractor shall notify each employee who has received blood monitoring of the results within five working days of the receipt of the results.

Each employee who has received full medical monitoring shall be provided with a copy of the physician’s written opinion within five working days of receipt of the results by the Contractor.

The Contractor shall maintain all medical monitoring and surveillance documents for the duration of an employee’s employment plus an additional 30 years.

5.3 TRAINING REQUIREMENTS DURING EXPOSURE ASSESSMENT

Section 5.3 applies to each employee who is required to enter a demarcated area during the exposure assessment phase of the project. Information concerning the health effects associated with exposure to lead shall be communicated to employees according to the requirements of the Hazard Communication Standard (29 CFR 1910.1200). This information shall include, but not be limited to, the requirements concerning warning signs and labels, material safety data sheets, health effects of exposure, and the contents of this Plan.

Lead training shall be performed prior to job startup and include information on:

• The content of the Lead in Construction Standard (29 CFR 1926.62) and its appendices.

• The purpose, proper selection, fitting, use and limitation of respirators.

• The purpose and a description of the medical surveillance program and the medical removal protection program including information concerning the adverse health effects associated with excessive exposure to lead.

• The engineering controls and work practices associated with the employee's job assignment, including good work practices.

• The contents of any compliance plan in effect.

• Instructions to employees that chelating agents should not routinely be used to remove lead from their bodies and should not be used at all except under the direction of a licensed physician.

• The employee's right of access to medical records

One person on site shall possess a card certifying that they are currently certified to perform CPR and First Aid in the case of an emergency response.

The Contractor shall maintain employee-training records for the duration of an employee’s employment plus an additional two years.

5.4 NEGATIVE INITIAL DETERMINATION

If the exposure assessment determines that no employee is exposed to airborne concentrations of lead at or above the action level or permissible exposure limits, a written record of this determination shall be made. This record shall include the date of determination, location within the work area, and the name and social security number of each employee monitored.

5.5 FREQUENCY OF MONITORING FOLLOWING NEGATIVE INITIAL DETERMINATION

If the exposure assessment reveals employee exposure to be below the action level, further exposure determination need not be repeated unless there is a change of equipment, process, control, personnel, or a new task has been initiated that may result in additional employees being exposed at or above the action level. If there has been such a change, further monitoring shall be required.

5.6 POSITIVE INITIAL DETERMINATION

5.6.1 Lead

If the exposure assessment determines that employees are exposed to lead at or above the PEL, the following additional requirements shall apply:

• The Contractor shall institute engineering controls in attempt to reduce exposures to below the PEL. When the Contractor chooses this option, all aspects of this plan apply, including section 5.0 (Exposure Assessment).

• Workers shall be informed in writing of their air monitoring results and told what engineering controls are under consideration to reduce their exposure to below the PEL.

• Lead warning signs shall be posted as required by section 3.2.1 of this plan.

• Shower facilities shall be available on site for use by employees whose exposure exceeds the PEL. All exposed employees shall be required to shower upon exit of a demarcated area where the airborne exposure to lead exceeds the PEL.

5.7 FREQUENCY

5.7.1 Exposures at or Above the Action Level for Lead and Below the PEL If the exposure assessment reveals employee exposure to be at or above the action level, but below the PEL, air monitoring shall be performed at least every six months. The monitoring shall continue until at least two consecutive measurements, taken at least seven days apart, are below the action level. At that time, air monitoring may be discontinued unless a change in equipment, process, control, personnel, or a new task is initiated that may result in additional employees being exposed at or above the action level.

5.7.2 Exposures Above the PEL

If the exposure assessment reveals worker exposures to be above the PEL, the Contractor shall continue to perform air-monitoring. The monitoring shall continue until at least two consecutive measurements, taken at least seven days apart, are below the PEL, but above the action level. At that time air monitoring shall be performed in accordance with section 5.6.1 above.

LEAD AIR MONITORING PROCEDURE

Personal samples shall be representative of a full shift including at least one sample for each job classification in the demarcated area.

Monitoring equipment to be used shall include the following:

• Low-volume air sampling pump

• 37mm filter cassette with a 0.8μm MCEF filter

• Appropriate tubing

• A rotameter capable of determining a flow rate range of 0.5 liters per minute (lpm) to 4 lpm

All monitoring shall be performed according to NIOSH Method 7082 (NIOSH 1994) and collected on sample data collection forms. Samples shall be analyzed by an accredited laboratory.

Air sampling cassettes shall be worn within the breathing zone, outside of protective clothing and with the face orientated down.

HOUSEKEEPING

7.1 HOUSEKEEPING REQUIREMENTS

The Contractor shall implement the following housekeeping procedures during activities impacting lead-containing dust and debris.

• All surfaces shall be maintained as free as practical of accumulations of lead-containing dust and debris.

• Floors and other surfaces where lead dust and debris have accumulated shall be cleaned by HEPA vacuuming or other wet methods that minimize the likelihood of materials becoming airborne.

• Shoveling, dry/ wet sweeping, and/or brushing may be used only where other methods have been tried and found not to be effective.

• Where vacuuming methods are selected, the vacuums shall be equipped with HEPA filters and used and emptied in a manner which minimizes the reentry of materials into the workplace.

• Compressed air shall not be used to remove lead-containing dust and debris from any surface unless the compressed air is used in conjunction with a ventilation system designed to capture the airborne dust created by the compressed air.

• The use of water shall be restricted to the smallest quantity necessary to minimize dust and to avoid the potential of contaminant migration through run-off or ponding. In no case shall liquids generated during building cleaning encounter uncontaminated soils, drains, surfaces or conduits which may constitute release to the environment.

• The release of lead-containing dusts and debris outside of the work area shall be prevented.

OTHER CONTRACTORS

The Contractor and all contractors performing any of the tasks listed in this Plan shall, in addition to the requirements of this Plan, be required to adhere to the following regulations and their appendices.

• 29 CFR 1910.134, "Respiratory Protection"

• 29 CFR 1910.20, "Access to Employee Exposure and Medical Records"

• 29 CFR 1910.1025, "Lead"

• 29 CFR 1910.1200, "Hazard Communication"

• 29 CFR 1926.62, "Lead"

• 40 CFR 50, "National Primary and Secondary Ambient Air Quality Standards"

• 40 CFR 117, "Determination of Reportable Quantities for Hazardous Substances"

• 40 CFR 261, "Identification and Listing of Hazardous Waste"

• 40 CFR 262, "Standards Applicable to Generators of Hazardous Waste"

• 40 CFR 263, "Standards Applicable to Transporters of Hazardous Waste"

• 40 CFR 264, "Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities"

• 40 CFR 265, "Interim Status Standards for Owners and Operators of Hazardous Waste

Treatment, Storage, and Disposal Facilities"

• 40 CFR 268, "Land Disposal Restrictions"

• 40 CFR 302, "Designation, Reportable Quantities, and Notification"

• NIOSH Method 7082, Lead

COMPLIANCE PROGRAM FOR LEAD

This section consists of a compliance program written in accordance with the requirements of 29

CFR 1926.62.

9.1 DESCRIPTION OF EACH ACTIVITY IN WHICH LEAD IS EMITTED

A description of each activity, which has the potential for occupational exposure to lead, can be found in sections 3.3 through 3.4 of this Plan. Additionally, it shall be the responsibility of the Contractor’s CP to require that Appendix 2: Lead Compliance Activity Log is completed for each job-specific task that may result in the impact to and or remediation of lead-containing dust and debris.

9.2 TECHNOLOGY CONSIDERED IN MEETING THE PEL- ENGINEERING CONTROLS

Inspection of the demarcated work areas shall be performed on a routine basis to ensure dust does not exit the work area. Workers shall be protected using personal protective equipment until monitoring shows exposures below the lead permissible exposure limit. If exposures are found to be above PEL, optional engineering controls may include the limited use of water, local exhaust ventilation, HEPA vacuum attachments for equipment and/or the use of HEPA filtered fans in the work area to remove dusts from worker breathing zones and further prevent the potential contamination of adjacent areas.

9.3 SPECIFIC MEANS EMPLOYED TO ACHIEVE COMPLIANCE

A description of the specific means that shall be employed to achieve compliance can be found in sections 2.0 through 8.0 of this Plan.

In addition to sections 2.0 through 8.0 of this Plan, the following is a list of studies used to determine methods selected for controlling exposure to lead:

• KTA Tator Inc. 1993. Industrial Lead Paint Removal Handbook. Pittsburgh, PA. (KTA Tator 1993)

• National Institute for Occupational Safety and Health. 1992. Health Hazard Evaluation Report, HETA 91-209-2249, Seaway Painting, Inc., Annapolis Maryland. Cincinnati, OH. (NIOSH 1992a)

• National Institute for Occupational Safety and Health. 1992. Preventing Lead Poisoning in Construction Workers. Cincinnati, OH. (NIOSH 1992b)

• Steel Structures Painting Council. 1992. SSPC - Guide 61 (CON) Guide for Containing Debris Generated During Lead Paint Removal Operations. Pittsburgh, PA. SSPC 92-07.

(SSPC 1992)

• Steel Structures Painting Council. 1993. Industrial Lead Paint Abatement, Approaches, Alternatives and Advances. Cincinnati, OH. SSPC-93-01, 928477-79-X. (SSPC 1993)

• U.S. Department of Housing and Urban Development. 1990. Lead-Based Paint: Interim Guidelines for Hazard Identification and Abatement in Public and Indian Housing.

Washington, DC. (HUD 1990)

• U.S. Department of Housing and Urban Development. 1991. The HUD Lead-Based Paint Abatement Demonstration (FHA). Washington, DC. HC-5831. (HUD 1991)

• U.S. Occupational Safety and Health Administration. 1993. Preamble to 29CFR 1926.62.

(OSHA 1993)

9.4 WORK PRACTICE PROGRAM

This Plan shall be considered the required work practice program.

9.5 ADMINISTRATIVE CONTROL SCHEDULE

Administrative controls shall not be utilized during this project unless the exposure assessment outlined in Section 5.0 reveals exposures above the action level.

9.6 ARRANGEMENTS MADE AMONG OTHER CONTRACTORS ON THE SITE

No other contractors are expected to be within the work area during the operations listed in this Plan.

CLEARANCE SAMPLING

10.1 DETERMINATION

The recommend maximum lead level thresholds developed by the Environmental Protection Agency and Housing and Urban Development for lead-based paint are utilized for this project.

The following table summarizes the recommended clearance levels as determined by the agencies mentioned above:

Clearance Area Clearance Level Concentration (µg/ft2)1

All surfaces up to 7ft above ground level 40

All surfaces up to 7ft above ground level 400

Food preparation areas2 Below laboratory minimum reporting level 1 - micrograms per square foot (μg/ft2) 2 - Food preparation areas shall be final cleaned with a “food-grade” disinfectant. Disinfectant used will be the same brand as currently used at the facility.

10.2 ENCAPSULATION

If lead-containing dust and debris cannot be cleaned to the clearance levels indicated in the table above, encapsulation may be an allowed alternative to continued cleaning. The contractor shall first verify and document that these surfaces have been cleaned thoroughly of all dust and debris to the same standard as similar surfaces in the building yet lead dust wipe sampling results remain above the clearance criteria. Encapsulants shall be applied following the manufacturer’s specifications.

If encapsulation is approved, the Contractor shall follow the guidelines as outlined in Chapter 13:

Abatement by Encapsulation of the HUD Guidelines for the Evaluation and Control of Lead- Based Paint Hazards in Housing (HUD 2012).

10.3 LEAD DUST WIPE SAMPLING

All lead dust wipe sampling will be performed in accordance with the following sampling protocol:

1. Employ a third-party certified Lead Risk Assessor to perform all dust clearance wipes

2. Begin dust clearance sampling no less than one hour after final cleaning

3. ASTM E 1728 “Standard Practice for Collection of Settled Dust Samples Using Wipe

Sampling Methods for Subsequent Lead Determination” (ASTM 2020b)

4. Analyze all clearance dust wipe samples at an NLLAP-accredited laboratory

REFERENCES

ASTM. 2020a. ASTM International. Standard Guide for Sample Selection of Debris Waste from a Building Renovation or Lead Abatement Project for Toxicity Characteristic Leaching Procedure (TCLP) Testing for Leachable Lead (Pb). West Conshohocken, PA.

ASTM. 2020b. ASTM International. ASTM E 1728-16: Standard Practice for Collection of Settled Dust Samples Using Wipe Sampling Methods for Subsequent Lead Determination. West Conshohocken, PA.

ASTM. 2020c. ASTM International. ASTM 1908-16: Standard Guide for Sample Selection of Debris Waste from a Building Renovation or Lead Abatement Project for Toxicity Characteristic Leaching Procedure (TCLP) Testing for Leachable Lead (Pb). West Conshohocken, PA.

EPA. 2023. United States Environmental Protection Agency. 40 CFR: Protection of Environment. Washington, D.C.

EPA. 2021. United States Environmental Protection Agency. Rule 86 FR 983, Review of Dust- Lead Post Abatement Clearance Levels. Washington D.C.

EPA. 2018. United States Environmental Protection Agency. 40 CFR 262, Standards Applicable to Generators of Hazardous Waste. Washington, D.C.

EPA. 2004. United States Environmental Protection Agency. Method SW 846-3050A, Acid Digestion of Sediments, Sludges and Soils by AA-Direct Aspiration. Washington, D.C.

HUD. 2012. Department of Housing and Urban Development. Guidelines for The Evaluation and Control of Lead-Based Paint Hazards in Housing. Washington D.C.

NIOSH. 1994. National Institute of Safety and Health. NIOSH Method 7082 - Lead by Flame AAS. Washington D.C.

OSHA. 2007. Occupational Safety and Health Administration. 29 CFR 1926.62. Occupational Safety and Health Regulations for Construction. Washington, D.C.

OSHA. 1971. Occupational Safety and Health Administration. 29 CFR 1910: Occupational Safety and Health Standards for General Industry. Washington, D.C.

SMITH. 2022. Asbestos, Lead-Based Paint, and other Regulated Building Materials Survey.

June 22, 2022. Dacono, CO.

KTA Tator Inc. 1993. Industrial Lead Paint Removal Handbook. Pittsburgh, PA.

NIOSH. 1992a. National Institute for Occupational Safety and Health. 1992. Health Hazard Evaluation Report, HETA 91-209-2249, Seaway Painting, Inc., Annapolis Maryland. Cincinnati, OH.

NIOSH. 1992b. National Institute for Occupational Safety and Health. 1992. Preventing Lead Poisoning in Construction Workers. Cincinnati, OH.

SSPC. 1992. Steel Structures Painting Council. 1992. SSPC - Guide 61 (CON) Guide for Containing Debris Generated During Lead Paint Removal Operations. Pittsburgh, PA. SSPC 92- 07.

SSPC. 1993. Steel Structures Painting Council. 1993. Industrial Lead Paint Abatement, Approaches, Alternatives and Advances. Cincinnati, OH. SSPC-93-01, 928477-79-X.

HUD. 1990. U.S. Department of Housing and Urban Development. 1990. Lead-Based Paint:

Interim Guidelines for Hazard Identification and Abatement in Public and Indian Housing.

Washington, DC.

HUD. 1991. U.S. Department of Housing and Urban Development. 1991. The HUD Lead-Based Paint Abatement Demonstration (FHA). Washington, DC. HC-5831.

OSHA. 1993. U.S. Occupational Safety and Health Administration. 1993. Preamble to 29CFR 1926.62.

Appendix A

Employee Acknowledgment

Employee Acknowledgment

I acknowledge that I have read and understand the Lead Compliance Work Plan for the Lead- Containing Dust and Debris Cleanup Project for the 5 campground buildings located in Zion National Park South Campground at 1 Zion Park Blvd, State Route 9, Springdale, UT 84767. I have received training in the Contractor’s policies and procedures associated with the performance of tasks that have the potential to impact lead-containing dust and debris. The training included the following:

1. Possible routes of exposure to lead.

2. The known health effects associated with exposure.

3. The importance of good personal hygiene.

4. The specific work practices that may be used.

5. The proper use and maintenance of protective clothing and equipment.

6. The correct use of engineering controls and implementation of good work practices.

7. The purpose, proper selection, fitting, use, and limitations of respirators.

8. The specific nature of the operations that could result in exposure to lead above the action level.

9. The purpose and description of the medical surveillance program, and the medical removal protection program.

10. Ban on use of chelating agents to remove lead from the blood except under direction of physician.

11. Access to information and regulations.

Name Signature Date

1. _____________________ _____________________ ___ ________________________

2. _____________________ _____________________ ___ ________________________

3. _____________________ _____________________ ___ ________________________

4. _____________________ _____________________ ___ ________________________

5. _____________________ _____________________ ___ ________________________

6. _____________________ _____________________ ___ ________________________

7. _____________________ _____________________ ___ ________________________

8. _____________________ _____________________ ___ ________________________

9. _____________________ _____________________ ___ ________________________

10. _____________________ _____________________ ___ ________________________

11. _____________________ _____________________ ___ ________________________

Appendix B

Task Specific Activity Log

TASK SPECIFIC ACTIVITY LOG

LEAD DUST AND DEBRIS REMOVAL / ENCAPSULATION PROJECT

This activity log complies with the OSHA Construction Lead Standard, OSHA 1926.62, and includes all of the information required in section (e)(2)(i-v). Copies of the completed activity logs shall be submitted for review by the Lead Competent Person prior to commencement of work.

Date: _______________________________________________________________________________

Contractor Name: ______________________________________________________________________

Address: _____________________________________________________________________________

Phone: ___________________________________ Fax: ______________________________________

Site Supervisor: ________________________________________Phone:_________________________

Activity Start date: ____________________Activity Completion date:____________________________

1. Competent Person: The contractor shall comply with all the provisions of the “Competent Person” as defined in OSHA 1926.62.

Who is the “competent person” for this activity? Name: _______________________________________

What specific duties will this person perform? _______________________________________________

2. Crew: What specific tasks will each worker be performing?

Name: _____________________________________ Drivers Lic. #:______________________________

Task: ______________________________________

Name: _____________________________________ Drivers Lic.#:______________________________

3. Location of the project: Where is the work taking place? Interior? Exterior? First floor? Second Floor? Room #? (Be specific):

4. Known areas of lead hazards: Has the building and site characterization testing & inspection data been reviewed by the competent person prior to beginning of work? Yes☐ No ☐

5. Has this information been communicated to the crew? Yes ☐ No ☐

6. Description of the work tasks that impact lead dust and debris: (HEPA vacuuming, wet wiping, encapsulating, component removal, etc.)

7. Equipment and materials:

List equipment being used; i.e., HEPA vacuums, wet wipes, tools, rags, scrub brushes, encapsulant, etc.

List materials for engineering controls; i.e., plastic sheeting, rubber gloves, cleaning detergents, personal protective equipment, etc.

List other products being used such as spray glue, encapsulant, sealer, paints, etc. Attach product details and Safety Data Sheet (SDS).

8. Control Measures: The contractor shall comply with all the provisions of the engineering controls outlined in OSHA 1926.62.

When applicable, describe work practices/control methods. Be specific to the tasks being performed. List good work practices that apply to this job. For example, how are wet methods to be used in controlling lead dust:

Wet methods:

HEPA filtered air scrubbers:

Enclosures or barriers:

HEPA vacuums:

Disposal methods:

Other:

9. Hygiene facilities and practices to be used on the project: The contractor shall comply with all the provisions of OSHA 1926.62

Location of hand-washing facilities: _______________________________________________________

Location of clean changing area: __________________________________________________________

10. Is hot water, soap, and towels provided? Yes ☐ No ☐

11. Are hygiene facilities being cleaned up at the end of each shift? Yes ☐ No ☐

Location of clean eating area: ____________________________________________________________

12. Housekeeping: The contractor shall comply with all the provisions of Housekeeping as outlined in

OSHA 1926.62.

Name and address of laboratory that will perform analysis:

IF NO, do you have historic data from work that is similar. Remember to link the exposure to a task.

Attach historic air-monitoring data to this activity log

17. Training: The contractor shall comply with all the provisions of the Training as outlined in OSHA 1926.62.

Prior to beginning work, submit all training records for all personnel working on the specific task or activity outlined above for inclusion into the Lead Compliance Plan.

18. Have you submitted your training records? Yes☐ No ☐

19. Medical Surveillance Program: The contractor shall comply with all the provisions of the Medical Surveillance as outlined in OSHA 1926.62

Prior to beginning work, if applicable, submit your medical surveillance program for inclusion into the Lead Compliance Plan

Have you submitted your medical surveillance program? Yes ☐ No ☐ N/A ☐ Have you submitted blood-monitoring results? Yes ☐ No☐ N/A ☐

20. Multi-contractor work sites: Have you communicated with other contractors in or adjacent to the work area about the potential for lead exposure? Yes☐ No ☐ N/A ☐

Describe any arrangements made with these contractors to reduce secondary exposure:

The competent person understands that they will adhere to the requirements of the Lead in Construction Industry Standards OSHA 1926.62. I have read and will comply with the provisions of the Lead Compliance Work Plan for this Project. I will provide all required submittals for this plan and will comply with all applicable OSHA regulations.

Signature:___________________________________________

Title:___________________________________ Date:________________

Appendix C

Submittals Checklist

Submittals Checklist

1. Appendix 1 – Employee Acknowledgement ☐

2. Appendix 2 – Task Specific Activity Log ☐

3. Respiratory Protection Program ☐

4. Lead Compliance Training ☐

5. Medical Surveillance Program (if applicable) ☐

6. Negative Initial Exposure Assessment (if applicable) ☐

11.0 REFERENCES

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